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Will a dollar really come back as a full dollar?
On October 12, the Financial Stability Board (FSB) released a note for the G20 titled "Global Stablecoins (GSC): Cross-border Vulnerabilities and Monitoring of Financial Stability." Published ahead of the G20 Finance Ministers and Central Bank Governors meeting in Bangkok on October 15, the document summarizes the FSB’s work to date and outlines issues for future consideration.
A "Global Stablecoin" (GSC) is defined as a stablecoin used not just within a single nation, but across the globe—to the extent that, should it falter, the impact could be significant enough to shake the entire economy of a given country.
It should be noted that the FSB’s document is non-binding; it imposes no deadlines and introduces no new reporting requirements.
Let us first examine the current state of the market. According to the FSB, the total value of these assets as of mid-2026 stands at approximately $300 billion—a figure largely unchanged from the previous year. In terms of value, 99% are pegged to the U.S. dollar. Data from private aggregators largely align with this: as of October 12, DefiLlama reports a total of $306.19 billion, while CoinGecko reports $303.4 billion as of October 14. Tether accounts for $184.1 billion (roughly 60%), and USD Coin (USDC) accounts for approximately $72.6 billion (about one-quarter).
However, the concern raised by the FSB relates not to the scale, but to the structure. Banks maintain accounts for identifiable depositors, allowing them to monitor their overall assets and liabilities and prepare for potential redemption requests.
In contrast, issuers of GSCs may have no clear visibility into who holds their coins, where those holders reside, or from which jurisdictions redemption requests might arise. Coins move across borders, while their holders remain pseudonymous—identifiable only by their addresses, with no real names visible. Meanwhile, the reserve assets backing these coins, as well as the legal frameworks designed to protect holders, remain anchored—at least in part—to specific countries or regions. In short, while the coins themselves circulate globally, their underlying support remains, to some extent, stationary. This note centers its analysis on this misalignment between liabilities and assets.
Particularly problematic is the "multi-issuer" model, in which several affiliated companies collectively assume the liabilities for a single coin. Because the reserve assets backing the coin are held separately by each entity, transferring assets between them during periods of stress may prove difficult or ineffective.
If any of the companies are authorized to process redemptions, there is a risk that claims could become concentrated on a single entity. Furthermore, because the locations of the holders are often unknown, it may become unclear—especially during a crisis or insolvency—which company bears responsibility toward which holder, or what specific rights the holders possess. In the event of a collapse, it could also be difficult to determine which country’s bankruptcy laws should apply.
The note points out that in many jurisdictions, it remains unclear how regulatory frameworks across different countries interact, particularly regarding coins issued abroad. Perhaps most significantly, the note observes that the regulatory frameworks governing Global Stablecoins (GSCs) have never been tested under conditions of severe stress or insolvency.
Moving forward, the Financial Stability Board (FSB) intends to strengthen its monitoring of cross-border vulnerabilities, support the implementation of its 2023 recommendations across various jurisdictions, and gather information on emerging approaches for handling scenarios where a GSC issuer faces financial distress or collapse. A letter from Governor Bailey (of the Bank of England) noted that the pace of regulatory progress varies across jurisdictions and that international cooperation is still in its early stages. A peer review among member jurisdictions in October 2025 revealed that, as of August 2025, only five jurisdictions—the Bahamas, Bermuda, the EU, Hong Kong, and Japan—had established frameworks aligned with the GSC’s recommendations.
